Document kxNkvaq1goK1yenRYNwMrZOq

1 RESPONSE TO INTERROGATORY NO. 44: 2 Wagner objects to this Interrogatory to the extent it 3 seeks information outside the plaintiff's alleged exposure peri 4 ods. Subject to that objection, Wagner states that it has per 5 formed scientific research and testing of its brake products 6 specifically directed to improving those products' performance, 7 safety and compliance with performance-related safety regula 8 tions. Wagner has had no department, division or section devoted 9 to medical research during the period stated. 10 INTERROGATORY NO. 45: 11 Please state the scientific or medical periodicals to which the defendant, its medical department or industrial hy 12 giene division subscribed during the period between 1930 and 1972 specifying the date said subscriptions were begun. 13 RESPONSE TO INTERROGATORY NO. 45 < 14 Wagner objects to this Interrogatory to the extent it 15 seeks information outside the Plaintiff's alleged exposure peri 16 od. Subject to that objection, Wagner states that it knows of 17 no such periodicals to which it may have subscribed. Wagner's 18 investigation continues. 19 INTERROGATORY NO. 46: 20 Please state whether any of the distributors of defen 21 dant's asbestos-containing products were provided with any spe cial instructions, oral or written, in regard to utilizing said 22 products in a manner so as to avoid exposing workers to dust. If so, please state: 23 (a) When these instructions were given; 24 (b) By whom these instructions were given; 25 (c) Whether the instructions oral or written; 26 (d) The precise content of the instructions; 27 (e) If the instructions were written, please attach a 28 copy of the instructions. 20